Jonathan P. Trotta

Experience

Advises and represents electric utilities and trade associations on issues involving wholesale electric markets, compliance and enforcement matters, transmission planning and development, FERC transmission open access policies and standards of conduct, generator interconnection, electric reliability, and physical/cybersecurity.

Works with clients to develop strategies for regulatory compliance and advocacy, and engages with policymakers and regulators at various Federal agencies on pending and final rules.

Represents shippers in natural gas pipeline rate proceedings.

Advises utilities on FERC anti-market manipulation rules, transmission standards of conduct policies, and NERC reliability compliance, and prepares internal compliance training programs.

Represented clients in nearly all major FERC rulemakings since 2010, securing many key policy victories.

Represented clients in all phases of FERC Order No. 1000 rulemaking and related DC Circuit appeal, successfully carving out a role for non-public utilities in regional transmission planning processes, while safeguarding their rights with respect to cost allocation and withdrawal.

Advised private equity developer and investor-owned electric utility on FERC transmission incentive rate policies, and engaged with FERC staff.

Advised client on must-run generator cost allocation methodologies used in various organized wholesale markets.

Advised numerous electric utilities on FERC open access transmission policies, and developed transmission tariffs to conform to open access rules.

Prepared FERC depreciation rate update filings and triennial market power update filings for investor-owned utility.

Advised and defended electric utility in FERC complaint proceeding challenging development of transmission facility, resulting in favorable rejection of complaint in its entirety.

Advised utility on issues regarding PURPA and mandatory purchase obligations from Qualifying Facilities.

Advised electric utilities and project developers on FERC generator interconnection issues and policy.

Served as lead government affairs and regulatory counsel for large, Class I publicly-traded railroad in connection with potential merger.

News

Speaking Engagements

Speaker, “Federal Energy Policy Update,” Greater Kansas City Chamber of Commerce, Energy and Environment Committee, Kansas City, MO, February 2017

Speaker, Various EUCI “FERC 101” and “FERC Compliance & Enforcement” Seminars, 2014-15

Panelist, “Thinking Outside The Box: Practical Advice for Career Advancement and Networking,” Suffolk University Law School Alumni Association, Washington, D.C., June 2013

Publications

Co-Author, "What We Talk About when We Talk About Resilience," Energy Bar Association Journal, November 2018

Co-Author, “FERC Comes Under Fire for High-Profile Prosecution in Powhatan,” Natural Gas & Electricity, Vol. 31, No. 11, 2015

Contributing Author, Report of System Reliability & Planning Committee, Energy Law Journal, Vol. 34, No. 2 (2013); Vol. 35, No. 2, 2014

Contributing Author, “Natural Gas Transportation,” Energy Law and Transactions (Matthew Bender)

Contributing Author, “Federal Regulation of Energy Transactions - Hydroelectric Power,” Energy Law and Transactions (Matthew Bender)

Client Alerts

Co-Author, “DOE Issues Proposed Grid Security Emergency Order Procedures in Accordance with FAST Act,” Stinson LLP Alert, December 2016

Co-Author, “FERC Eases Electric Storage and Distributed Energy Resource Aggregator Participation in Wholesale Markets,” Stinson LLP Alert, November 2016

Co-Author, “NERC Poses Draft Physical Security Reliability Standard: CIP-014-1,” Stinson LLP Alert, April 2014

Co-Author, “FERC Orders Physical Security Standards That Will Impact All Bulk Power System Assets,” Stinson LLP Alert, March 2014

Co-Author, “NIST Releases Cybersecurity Framework,” Stinson LLP Alert, February 2014